Formulation and Announcement of Policies Regarding Customer-Oriented Business Conduct

In order to achieve even better business conduct, MJIA affirms and publishes the status of efforts relating to this Policy on its corporate website at least once a year in addition to reviewing this Policy at least once a year.

Commitment to Customers’ Best Interest

MJIA positions compliance as one of the most important priorities for management with a view to maintaining the impartiality of the financial instruments markets and ensuring the trust of customers. The company complies with Japan's Financial Instruments and Exchange Act, as well as other laws and regulations, and conducts its business sincerely, impartially, and in good faith, executing business operations faithfully with the care and diligence of a prudent manager in order to serve the best interests of its customers.

Appropriate Management of Conflicts of Interest

MJIA implements the following measures in transactions between customers and interested parties* of the company to ensure that customer interests are not harmed due to conflict of interest. *MJIA has designated in advance companies from among the Mitsubishi Estate Group that meet certain criteria, including investment from Mitsubishi Estate Co., Ltd., and parties which entrust business to the company, as interested parties.

• When handling transactions between customers and interested parties that exceed certain criteria, MJIA tasks the Compliance & Risk Management Committee with deliberation and confirms through an outside attorney that there are no issues from the perspective of laws and regulations. This is done in order to carefully consider the advisability of the transaction concerned from the standpoint of conflict of interest prior to the company’s decision.
• MJIA, as a rule, obtains the approval of the general manager of the Compliance Department when handling transactions between customers and interested parties, even for transactions that do not exceed the said criteria.
• When handling buying and selling between parties which entrust business to the company, MJIA takes measures to shield information between the seller and the buyer (system access restrictions and physical shielding measures) to manage the transaction concerned appropriately.

Clarification of Commissions and Fees

• MJIA endeavors to provide customers with information on the fees incurred by the customer and other details of costs, including the services provided by specific fees, in an understandable manner.
• MJIA sets the amount of business remuneration and the method for calculating the amount of business remuneration for each customer in light of the relevant laws and regulations, based on the type and attributes of the transaction target and market transaction practices. When the company engages in two or more businesses, as a general rule it sets the amount of business remuneration and the method for calculating the amount of business remuneration for each business.

Provision of Important Information in an Understandable Manner

• MJIA complies strictly with laws and regulations and discloses information promptly and accurately with a view to maintaining the impartiality of financial instruments markets and ensuring the trust of customers. The company also gives consideration to the transparency and understandability of the information it provides and is committed to sound and appropriate conduct of business and information disclosure.
• MJIA does not currently sell or recommend packages of multiple financial products and services.
• MJIA provides information in accordance with customer and product characteristics, taking into account the transaction experience and financial knowledge of customers.

Provision of Appropriate Services to Customers

• MJIA originates, sells, and recommends financial products and services that are appropriate for customers, taking into account the transaction experience and financial knowledge of customers.
• MJIA does not sell or recommend financial products that are particularly complex or high risk and does not sell or recommend financial products to groups with attributes that are deemed to be vulnerable to damage from financial transactions.
• MJIA strives to provide customers with information that includes basic knowledge relating to financial transactions, taking into account the transaction experience and financial knowledge of customers.

Framework for Motivating Employees Appropriately

MJIA positions compliance as one of the most important priorities for management. The company works to develop a framework for appropriately motivating employees and a structure for appropriate governance as described below in order to ensure compliance with laws and regulations and the sound and appropriate conduct of business.

• MJIA includes compliance in the items to be assessed in personnel evaluations.
• MJIA works to raise the awareness of executives and employees by holding periodic training on compliance.
• In an effort to encourage its executives and employees to increase their expert knowledge, MJIA provides programs to help them acquire and maintain a variety of qualifications (ARES Certified Master, Real Estate Transaction Agent, etc.), as well as external training opportunities to acquire wide-ranging expertise.

Formulation and Announcement of Policies Regarding Customer-Oriented Business Conduct

In order to ensure even better business operations, MJIA posts updates on the status of initiatives related to this policy on its website and via other channels. In addition, the company reviews this policy at least once a year.

For more information on these policies and status of initiatives, see the MJIA website below.

http://www.mecinvest.com/en/company/fiduciary.html

Commitment to Customers’ Best Interest

• At the Nippon Open Ended Real Estate Investment Corporation (JOE) and the Mitsubishi Estate Logistics REIT Investment Corporation (MEL) as well as other funds managed by MJIA, compliance is positioned as one of the most important management issues in the effort to continuously increase investor value by delivering stable medium- to long-term growth.
• MJIA considers the greatest possible incorporation of environmental, social, and corporate governance (ESG) factors into investment decision-making and management processes necessary for maximizing medium- to long-term investor value and has established basic policy on sustainability and set goals to achieve this. MJIA posts information pertaining to these matters on its website.

http://www.mecinvest.com/en/sustainability/index.html

Note that MEL posts relevant information pertaining to these matters on its website. JOE investors are able to check relevant information by accessing the JOE website using a dedicated password.

MEL:

 https://mel-reit.co.jp/en/esg/sustainability/policy.html

JOE:

 https://joe-re.com/ (in Japanese only)

• The asset management fee for MEL is structured from three layers, (1) Asset management fee I (AUM-linked), (2) Asset management fee II (real estate profit-linked), and (3) Asset management fee III (unitholder interest-linked). MEL introduced an asset management fee fully linked with investment unit performance in the third layer, that reflects the relative performance between MEL's investment unit price and the TSE REIT Index, which was the first in J-REIT. In doing so, MEL aims to strengthen the alignment between the Asset Management Company and unitholder interest. The relevant information is available on MEL’s website.

https://mel-reit.co.jp/en/esg/governance/corporate.html

• MJIA accepts talented human resources with experience and expertise in real estate investment and real estate management, as well as advanced IT personnel, seconded from other Mitsubishi Estate Group companies. MJIA also accepts attorneys and real estate appraisers with a high degree of specialization in various legal systems and real estate valuation in order to maximize investment performance by fully utilizing these external human resources. MJIA posts information pertaining to these matters on its website.

http://www.mecinvest.com/en/sustainability/employee.html

Appropriate Management of Conflicts of Interest

• MJIA ensures that the company’s Rules Governing Transactions by Related Parties are duly observed at the investment companies and other funds it manages in order to prevent transactions by related parties that are unjust and/or unfair.
  
  Note that MEL posts relevant information pertaining to these matters on its website. JOE investors are able to check relevant information by accessing the JOE website using a dedicated password.

MEL:

 https://mel-reit.co.jp/en/features/management.html

JOE:

 https://joe-re.com/ (in Japanese only)

• MJIA has established the Compliance and Risk Management Committee, which deliberates transactions that may cause conflicts of interest and other compliance-related matters.

Clarification of Commissions and Fees

MJIA has systematically determined the management fees it receives from its investment companies and funds. For more information on the management fees charged to the investment companies, check the MEL securities reports and JOE product descriptions.

Note that MEL posts relevant information pertaining to these matters on its website. JOE investors are able to check relevant information by accessing the JOE website using a dedicated password.

MEL:

 https://mel-reit.co.jp/en/ir/library.html

JOE:

 https://joe-re.com/ (in Japanese only)

Provision of Important Information in an Understandable Manner

• MJIA conducts IR activities for MEL investors and publishes the content of IR briefings and relevant explanatory materials on the MEL website. We strive to provide information in an easier-to-understand and environmentally friendly format in our Asset Management Report by responding to unitholders’ requests as follows.

• The company also conducts IR activities for JOE investors and releases current financial statements for each fiscal term as well as forecasts for the coming term (currently available only in Japanese).
  
  Note that MEL posts relevant information pertaining to these matters on its website. JOE investors are able to check relevant information by accessing the JOE website using a dedicated password.

MEL:

 https://mel-reit.co.jp/en/ir/index.html?cate=all&year
 https://mel-reit.co.jp/en/ir/library.html

JOE:

 https://joe-re.com/ (in Japanese only)

• MJIA proactively provides investors with information on its commitment to sustainability and ESG-related initiatives via its investment companies’ websites.
  The MEL website has a section dedicated to ESG initiatives, where the company’s Sustainability Report is available for download. JOE investors are able to check relevant information by accessing the JOE website using a dedicated password.

MEL:

 https://mel-reit.co.jp/en/esg/

JOE:

 https://joe-re.com/ (in Japanese only)

Provision of Appropriate Services to Customers

• In managing its investment corporations and other investment targets, MJIA strives to clearly understand the needs of its investment customers and to appropriately provide these parties with the information believed necessary for investors in its investment corporations and other investment targets.
• In the formation of its investment products, MJIA identifies customer attributions per characteristics of each product and appropriately provides customers with timely information and proposals regarding products that match their investment objectives, experience and knowledge.

Framework for Motivating Employees Appropriately

• In order to encourage skill and career development for individual employees, MJIA has introduced a Management by Objectives (MBO) system for all employees and includes compliance as an evaluation item in its relevant assessments.
• MJIA conducts regular compliance and risk management training to raise compliance awareness among executives and employees.

• In an effort to encourage its executives and employees to increase their expert knowledge, MJIA provides programs to help them acquire and maintain a variety of qualifications (ARES Certified Master, Real Estate Transaction Agent, etc.), as well as external training opportunities to acquire wide-ranging expertise. MJIA posts information pertaining to these matters as well as numbers of employees with major qualifications on its website.

http://www.mecinvest.com/en/sustainability/employee.html

• MJIA has introduced a payroll deduction stock program (MEL) available for its executives and employees, where they can own the MEL investment units. In doing so, MJIA aims to raise their awareness of improving MEL investment unit price and the company’s performance, and thereby continuously enhance the value the company delivers to its investors over medium- to long-term.